Financial Services: 2014 SEC comment letter trends

At a glance

This paper discusses the recent areas of focus and applicable accounting or reporting guidance in SEC staff’s comment letters issued over the past few years to registrants within the financial services industry and the identified trends of hot topic areas.

The Securities and Exchange Commission (SEC) continues to emphasize the primary role and responsibility assumed by management and audit committees in providing meaningful and transparent information to investors. The uncertainties in the current economic and regulatory environment make the preparation of high-quality reports increasingly important and challenging.

To help you prepare for your annual reporting, PwC’s Financial Services Industry Group has developed Stay informed Financial Services 2014 SEC comment letter trends. In this latest edition of our annual publication we have analyzed SEC staff comment letters issued to registrants across different sectors within the financial services industry, including: banking and capital markets, insurance, asset management, and real estate. We have highlighted the top areas where registrants received the majority of comments and have also provided relevant examples of recent comment letters along with the applicable accounting or reporting guidance.

Understanding the SEC staff’s recent areas of focus is an important aspect to consider as part of the year-end reporting process. The SEC staff continues to emphasize the importance of providing information to investors that is reliable, meaningful and transparent, particularly in areas that involve significant judgment. Continuing key themes emphasized by the SEC staff through recent comment letter trends impact both financial and non-financial statement disclosures, with management’s discussion & analysis once again being the most frequent area of comment.

We hope that a better understanding of these trends, along with specific examples of comments, will provide you with helpful insights and will aid in your producing high-quality annual reports for investors and other stakeholders.